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UK Stewardship Code 2026 Factsheet
The UK Stewardship Code 2026 establishes the core principles of effective stewardship and sets a high standard of transparency for asset owners and asset managers, and for the service providers that support them.
The FRC developed the Code through a comprehensive consultation process that engaged over 1,500 stakeholders. The result is a distilled Code that maintains high standards while sharpening the focus on signatories' stewardship activities and their outcomes.
With the updated Code in effect from 1 January 2026, this factsheet answers some key questions for signatories intending to submit their reports this year.
Transition year for existing signatories
The 2026 transition year gives current signatories the opportunity to consider whether they wish to update their approach to reporting ready for 2027. Existing signatories who submit a renewal application will remain on the signatory list in 2026. These organisations have already met the requirements to become a signatory of the 2020 Code, and so we want them to take advantage of the updated, more flexible reporting framework of the 2026 Code.
New applicants in 2026 – those not listed as signatories to the 2020 Code in 2025 – will still be subject to an assessment process, ensuring they meet the requirements of the Code.
Further support and feedback will be provided through a range of channels, including publications, webinars, and one-to-one engagement.
Q&A
Who does the Stewardship Code apply to?
Asset owners such as pension schemes, insurers, foundations, endowments, local government pension pools and sovereign wealth funds.
Asset managers who manage assets on behalf of UK clients or invest in UK assets.
Service providers: investment consultants, proxy advisors and engagement providers that support asset owners and asset managers to exercise their stewardship responsibilities.
What do existing signatories need to do this year?
Signatories must submit their report in their usual application window in 2026. This should include both the Policy and Context Disclosure and Activities and Outcomes Report, either as two separate reports or a single document. All existing signatories who submit reports this year will remain on the signatory list in 2026.
You can use this as an opportunity to re-think how you report if you wish to. Tell your story – use the Code as a framework to set out what you do and what you have achieved in your stewardship efforts this year.
While materials from 2025 stewardship reports can be reused if applicable, cross-referencing to previous reports should be avoided. As signatories are now reporting to the new Code, readers should be able to understand the application of the Code without having to refer to information elsewhere.
What do new applicants need to do?
Applicants should report in their preferred application window (see our website for the application deadlines and valid reporting periods). Applications should report to the Code as a whole, including both a Policy & Context Disclosure and an Activities & Outcomes Report, responding to the Principles relevant to their organisation and how they undertake stewardship.
The transition year applies only to existing signatories. New applicants will only be added to the signatory list if they meet the requirements of the 2026 Code.
What are the application windows for 2026?
There are still two application windows, for both existing signatories and new applicants.
Spring deadline: - 30 April 2026 for asset managers and service providers. - 31 May 2026 for asset owners.
Autumn deadline: - 31 October 2026 for all signatory types.
How will the FRC provide feedback?
We are committed to providing useful feedback to any applicants to the Code, aiming to offer insights and additional materials to benefit all, whether through podcasts, webinars, individual feedback letters or other avenues. Where there are concerns that an existing signatory would not be successful in an application outside of the transition year, we will be in touch to explain our concerns.
Is cross-referencing permitted in reporting?
Reports should provide enough information to enable the reader to have a good understanding of the application of the Code without having to refer to information elsewhere, though signatories can link to further information or full policies. Where signatories choose to submit their Policy & Context Disclosure and their Activities & Outcomes Report as two separate documents, then cross-referencing between them would be acceptable. If choosing to link to additional documents to provide additional information, these should be clearly signposted and easily accessible.
What format or structure should reports be in?
There is no single strict format or structure for reporting. The 2026 Code introduces a two-part framework for reports, and signatories can submit these as two separate reports or combine them into one document.
- Policy and Context Disclosure, covering information about the signatory, its governance, resourcing and policies. This is required every fourth year.
- Activities and Outcomes Report, an annual update demonstrating a signatory's policies in action, showcasing what they have done during the year and what they have achieved.
The Code is intended to be flexible. Just as there is no 'one size fits all' approach to stewardship, there is no 'one size fits all' approach to reporting. Reporting should be proportionate to your circumstances, and it should tell your story. Applicants can report Principle-by-Principle or take a narrative approach. It is also acceptable to include stewardship reporting within a wider sustainability report if this suits your business needs and audiences.
How many case studies should we include?
Signatories are encouraged to use illustrative case studies where this is a helpful and appropriate way to give a clear picture of how the organisation has undertaken stewardship. These should be broadly representative of the asset classes in which an organisation invests. They should be as specific and as transparent as possible but need not compromise confidentiality.
Signatories who invest through external managers and do not engage directly with companies or conduct their own voting are not required to report to Principle 3 (Engagement) or Principle 4 (Exercising rights and responsibilities). They may wish to include case studies conducted on their behalf by external managers in their reporting for Principle 5 (Selection and oversight of managers). If so, it's helpful to also provide context to link those case studies to their stewardship approach, explaining why they have selected them and if they have discussed them with their external manager.
How does the FRC assess reports?
The Code operates on an 'apply and explain' basis. Successful signatories are transparent in their stewardship approach, and in explaining how they have applied the Principles, including activities and outcome from the reporting year.
What support and guidance is available?
Reporting guidance is available on the FRC website, along with our report on Preparing for the 2026 Code. The reporting guidance is intended to support signatories in understanding how to report well, but is not a checklist of requirements to include.
The FRC will continue to provide support and feedback via our website and other channels.
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